Wednesday, October 24, 2018

As a long-time supporter of the FCC's Lifeline program, I'm was pleased to see that the Commission has proposed to levy a $63.7 million fine on Lifeline provider American Broadband and Telecommunications for engaging in apparently fraudulent conduct relating to enrollment of Lifeline subscribers.

When I say I am "pleased," I am not pleased, of course, that American Broadband engaged in fraudulent conduct, but rather I am pleased that the agency has proposed levying a stiff fine in an enforcement action. For the Lifeline program to be sustainable and to maintain public support, the FCC needs to be vigilant in rooting out waste, fraud, and abuse such as that allegedly committed by American Broadband.

It's certainly no secret that I generally favor free market policies in the communications and Internet space. And the Commission's turnabout under the leadership of Chairman Ajit Pai towards adoption of such market-oriented policies has been most welcome – and most sorely needed. But, as I stated in these comments filed in February 2018 in the FCC's current Lifeline proceeding, "the primary purpose of the Lifeline program is to ensure that low-income persons have access to communications services." In other words, it is what I consider to be a "safety net" program. In that light, and in that context, I opposed the Commission's proposal to exclude resellers from participation in the Lifeline proposal, especially given that they now serve about 70% of Lifeline subscribers.

So, I hope the Commission will continue to act vigorously to root out waste, fraud, and abuse by individual providers – the proverbial "bad actors." That's necessary and appropriate. But I hope, at the same time, it will put aside proposals that would have the effect, even if inadvertently, of gutting the program.